Exhibit 10.21
Geovic Mining Corp.
Code of Business Conduct and Ethics
Geovic Mining Corp. is committed to Integrity, Trust, Respect, and Excellence in all relationships with customers, employees,
suppliers, shareholders and the community.
We comply with all applicable laws and regulations governing our business conduct worldwide.
We act with integrity in all business transactions and relationships and we avoid all conflicts of interest between work
and personal activities.
We are committed to the protection of Geovic Mining Corp.’s financial, physical, and intellectual property assets and
ensure that all financial information is complete, accurate, and reflects actual transactions.
We create a culture within Geovic Mining Corp. that fosters a safe work place, equal opportunity, diversity,
communication, and innovation where everyone is treated with respect, fairness, and dignity.
We are committed to sustainable development, social responsibility, and excellence in environmental management.
Table of Contents
I.
Introduction
A. General Policy Regarding Laws and Business Conduct
3
B. Compliance with the Code
3
II.
Employment Practices
A. Equal Employment Opportunity
4
B. Harassment
4
C. Improper Use or Theft of Company Property
4
III.
Ethical Management Practices
A. Accounting Controls, Procedures, and Records
5
B. Retention and Disposal of Documents and Records
5
C. Confidential or Proprietary Information
6
IV. Conflicts of Interest
A. Business Courtesies
6
B. Gifts
6
C. Business Entertainment
6
D. Outside Interests
7
V.
Political Involvement
A. Political Activities
7
VI. Safety and the Environment
A. Safety and the Environment
8
B. GeoAid
8
VII. Securities Trading
A. Insider Trading
8
VIII. Fraud and Similar Irregularities
A. Fraud and Similar Irregularities
8
The Code of Business Conduct and Ethics (the “Code”) of Geov